Mr. Chairman and committee members, as stated, my name is Robert Frelich, and I am the director general of identity policy and programs within Service Canada. I'm pleased to be appearing before the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities to assist you in your review of Bill C-247.
I will begin by explaining how the current process works with respect to death notification, what Service Canada does in the event of a death, some key issues in implementing Bill C-247 as written, and improvements we are making to better communicate with Canadians with respect to death notification.
As director general for Identity Policy and Programs at Service Canada, one of my duties is to administer the social insurance number program. This program is underpinned by the social insurance register, which houses the information on SIN holders. This register is where we store death information received electronically from provincial vital statistics agencies.
Through interjurisdictional agreements, Service Canada currently receives daily death information electronically from nine provincial vital statistics agencies. Implementation in the 10th province, Saskatchewan, is planned for fiscal year 2015-16. This approach was implemented following the Auditor General's report on the social insurance number that recommended Service Canada make better use of authoritative sources of information. With respect to death information and death data, those are the provincial vital statistics agencies.
The department began to sign agreements in 2005 with all 10 provinces, starting with Ontario, to develop electronic links between the vital statistics agencies and the social insurance register.
Under these agreements, we are able to validate the information found on provincial birth certificates, as well as to receive death data from provinces. This allows the department to identify records of deceased individuals, and to prevent further payments from federal programs from being issued, which is important as it avoids overpayments.
Service Canada discloses death information to key Government of Canada benefit programs, including the Canada pension plan, old age security, the employment insurance program, the Canada student loan program, the Canada Revenue Agency, as well as Veterans Affairs Canada through an agreement with the old age security program. These programs then, according to their own processes, update their client files or suspend benefits. These programs cover the Government of Canada benefits program that are of the greatest importance to Canadians in terms of numbers.
With respect to the bill as currently drafted, there are four key implementation considerations that I would like to bring to the attention of the committee today.
First, there are technical issues related to data matching that must be considered. To be able to match data accurately, to be able to say with certainty that the John Smith who has died is indeed the right John Smith, we need to have a unique identifier. For the purposes of the federal government, that is the social insurance number; however, not all federal departments and programs are authorized to use the social insurance number. It is currently limited to specific programs, and authority is granted through legislation or regulations. To implement the bill as drafted, all departments and programs that want to receive death notification would need to become authorized users of the SIN.
The second consideration relates to service delivery. The bill introduces the notion that the representative of the estate would be the one communicating information on death to Service Canada. By prescribing this specific mechanism, implementing Bill C-247 would require the introduction of new measures to ensure that the representative is who they say they are, that they are the official representative of the state, that the death information is accurate, and that the representative has all the required documentation.
From a client perspective, this process will be more cumbersome than what is currently in place. We receive information on deaths directly through nine provinces through the vital events linkages. For deaths in jurisdictions where the vital events linkages system is not in place, or for deaths outside of Canada, we require official documentation on the death, that is, a death certificate, but we do not require the individual to prove their own identity or authority as the representative.
The third consideration is the time that would be required to implement the bill as drafted. To protect the privacy of Canadians, there are specific legislative requirements that authorize the disclosure of information. To be able to disclose information—such as the fact that an individual is deceased—departments must enter into information sharing agreements. Our vital events linkages agreements with provinces, for example, took between three months and over a year to finalize, depending on the complexity of the negotiations and capacity of the partner, in addition to time for proper implementation.
The last consideration I would like to bring to the committee's attention relates to the cost of implementing the process proposed in the bill. There would be cost implications for Service Canada and all federal departments requesting death information. To allow electronic transmission of the information as our current processes allow, new connections to Service Canada's social insurance register would need to be established. This would cost up to $900,000 per link and $50,000 per connection for annual maintenance.
The current system works well, but we recognize there is a need to improve communication to Canadians about how it works and what they need to do when faced with the death of a loved one.
Modifying the bill will allow for quicker implementation and demonstrate a level of responsiveness to Canadians. We recognize that there are gaps in the information that Service Canada currently provides to Canadians on what to do following a death, so we are currently improving our website to increase coherence and consistency of our messaging regarding the processes in the event of the death of a Canadian resident or Canadian citizen.
We are also working with key stakeholders, such as the Funeral Service Association of Canada, building on existing practices and identifying opportunities to better inform survivors of which federal programs and departments are automatically informed of the passing, which other programs and which departments survivors may need to inform, as well as which benefits survivors may be eligible for and for which they may need to apply.
In closing, I would like to underline that as a client-facing organization, Service Canada continues to be committed to improving services that better meet our clients' needs and expectations.
I thank you for the opportunity to appear before the committee, and I would be pleased to answer any of your questions.